LEDGERPrecision Is the Terms.
Compliance Is the Service.
These terms govern every engagement undertaken by Ledger Advisory LLC. Each clause is drafted with the same forensic rigor applied to the returns, audits, and structures we defend on your behalf.
Tax Strategy
IRC §§ 61–1563, multi-state apportionment, Wayfair nexus analysis
Audit Defense
IRS Appeals, Tax Court representation, Rev. Proc. 2016-13 compliance
Advisory
Trust structuring, entity formation, IRC § 2036–2038 estate exposure
What we file, and what we stand behind.
Every return prepared by Ledger carries a documented position. We do not file on assumption — each figure is traceable to a source document, each deduction to a statutory authority. Our engagement scope covers the full complexity of your entity structure, not just the headline return.
Multi-state filers receive a nexus analysis memo alongside their return package. Foreign information returns are tracked on a rolling compliance calendar with 90-day advance notice of filing deadlines.
Scope limitation: This engagement does not include tax court litigation representation unless separately contracted under Addendum C · Audit Defense.
Encryption Standard
All client documents transmitted via 256-bit AES encryption. At-rest encryption applied to all stored files.
Retention Schedule
Tax records retained for 7 years from filing date per IRS guidelines. Permanent retention for entity formation documents.
Third-Party Disclosure
Client data is never sold or shared with third parties outside engagement scope without written consent.
Access Controls
Role-based access with MFA required. Audit log of all file access events retained for 3 years.
Breach Notification
Clients notified within 72 hours of confirmed data incident. Written incident report provided within 10 business days.
Your documents are not a data product.
We treat every document you share as a sealed exhibit. Tax returns, financial statements, trust instruments, and correspondence are classified under IRC § 7216 confidentiality requirements — the same standard applied in federal tax proceedings.
Our infrastructure is SOC 2 Type II certified. Every access event is logged. You can request a full audit trail of your file at any time during the engagement.
Fees are fixed. Surprises are not our product.
Every engagement is priced against a defined scope of work confirmed in writing before work commences. Scope expansions require a written change order with revised fee schedule — you will never receive an invoice for work you did not authorize.
Audit defense retainers are held in a client trust account. Unused retainer is returned at engagement close with a full accounting of hours and activities.
FTB nexus threshold: $601,967 sales or 25% of total sales
Economic nexus + MTA surcharge; NYC UBT for partnerships
No income tax; franchise tax applies to gross receipts
No individual income tax; F-1120 for C-Corps
Franchise tax on authorized shares; gross receipts method
Complexity is where most firms stop.
Multi-entity structures — family offices with undocumented transfers, PE-backed portfolio companies, consolidated groups with intercompany transactions — represent the work most tax practices decline to accept. We built our practice around precisely these structures.
Every complex engagement begins with a structure memo that maps the entity graph, identifies exposure points, and establishes a documentation baseline. This memo is yours to keep regardless of engagement outcome.
- Entity graph with ownership percentages and tax classification
- Identified IRC exposure points with statutory citations
- Documentation deficiency log with remediation priority
- Recommended filing position with precedent references
Consolidated Return Groups
Affiliated group elections under IRC § 1501. Intercompany transaction elimination, deferred gain tracking, and consolidated NOL computation.
Family Office Structures
Undocumented trust reconstruction, generation-skipping transfer analysis, Crummey trust compliance, and §2036 retained interest exposure mapping.
Private Equity Portfolio
Fund-level K-1 aggregation, UBTI analysis for tax-exempt LPs, carried interest characterization under IRC § 1061.
Cross-Border Structures
CFC analysis under Subpart F, GILTI inclusion computation, foreign tax credit optimization across treaty jurisdictions.
Tell us about your structure. We'll tell you what we see.
The review call is 45 minutes. We come prepared. You'll leave with at least one documented position you can act on.
Still evaluating?
Download our full Service Specifications document — 18 pages covering engagement protocols, filing matrices, jurisdiction tables, and data handling frameworks.
- 18-page service specification
- Complete filing matrix by entity type
- Jurisdiction complexity index · 47 states
- Data handling & retention protocols
Email + company name only. No spam.
Every engagement starts with a documented review. No commitment required.